Professional Documents
Culture Documents
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for the
year in issue, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
- 2 -
Background
per year.
fees and the remainder was used to pay off the credit card bills
with the 2006 tax return intervenor remitted a check from her
parties, indicating they could pay $500 per month toward the
return.
2
In actuality, of the reported tax liability of $11,875,
$3,138 was attributable to petitioner and $8,737 was attributable
to intervenor.
- 5 -
living room furniture, using the money from the lump-sum Social
living expenses for herself and her son. From January 1, 2008,
Discussion
and severally liable not only for the entire tax due, but also
210 (2009).
147-152 (2003).
which include, inter alia, that the income tax liability from
attributable to him.
see Rev. Proc. 2003-61, sec. 4.02 and 4.03, 2003-2 C.B. at 298,
liable for the joint and several income tax liability that arises
- 8 -
from the 2006 joint Federal income tax return filed with
economic hardship if relief were not granted nor that he did not
know and had no reason to know that intervenor would not pay the
disability benefits.3
3
In this regard, when asked by respondent’s counsel at
trial whether he knew he could file using the married filing
separately filing status petitioner replied as follows:
Conclusion
for respondent.